The competing standards of Internet libel jurisdiction reflect the tensions between the forum state's interest in providing convenient recovery for its injured residents and the defendant's constitutional right to foresee where he might be subject to jurisdiction. In an effort to pursue these two goals as well as integrate modem Internet-related concerns, lower courts have derived numerous divergent tests for Internet libel jurisdiction, leaving the issue in a state of disorder and ambiguity. To analyze this problem, this Note will first survey the historical background of traditional personal jurisdiction principles, with particular emphasis on the U.S. Supreme Court's Calder "effects" test. Then, this Note will discuss how the lower courts have interpreted and misinterpreted Calder, as they attempt to incorporate Internet-related issues and merge the effects test with other personal jurisdiction standards. Finally, this Note will examine Baldwin's reasoning in light of the competing standards for Internet libel jurisdiction and will recommend what future courts can do to resolve the still-unsettled issues of Internet jurisdiction in Missouri.

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